Galeas v. 1401 Grand Concourse LLC.

CourtDistrict Court, S.D. New York
DecidedJanuary 8, 2024
Docket1:22-cv-08510
StatusUnknown

This text of Galeas v. 1401 Grand Concourse LLC. (Galeas v. 1401 Grand Concourse LLC.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Galeas v. 1401 Grand Concourse LLC., (S.D.N.Y. 2024).

Opinion

USDC SDNY UNITED STATES DISTRICT COURT DOCUMENT SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED EDWIN GALEAS, DOC # DATE FILED: _ 1/8/2024 Plaintiff, -against- 22 Civ. 8510 (AT) 1401 GRAND CONCOURSE LLC, 1401 GRAND CONCOURSE ASSOCIATES LLC, DAVID ORDER GREEN and YONA ROTH, Defendant. ANALISA TORRES, District Judge: Plaintiff, Edwin Galeas, brings this action against Defendants, 1401 Grand Concourse LLC, 1401 Grand Concourse Associates LLC,! David Green, and Yona Roth, alleging violations of the Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 201 ef seg., and the New York Labor Law, (“NYLL”) § 190 et seg., for minimum wage violations, failure to pay overtime wages, and failure to provide wage statements and notices. See ECF No. 1. Having reached a settlement (the Settlement”), ECF No. 43-1, the parties move for the Court’s approval. See Letter, ECF No. 43. For the reasons stated below, the motion is DENIED without prejudice to renewal. DISCUSSION I. Legal Standard The FLSA was enacted “‘to correct and as rapidly as practicable to eliminate” certain “labor conditions detrimental to the maintenance of the minimum standard of living necessary for health, efficiency, and general well-being of workers.” 29 U.S.C. § 202. Significantly, “[r]ecognizing that there are often great inequalities in bargaining power between employers and employees, Congress

' By stipulation dated July 25, 2023 and endorsed by the Court on July 27, 2023, the parties sought to dismiss the action, with prejudice, against Defendant 1401 Grand Concourse Associates LLC. ECF No. 45. The Court’s endorsement was in error. This action shall not be dismissed with prejudice against any Defendant unless the settlement agreement has been approved by the Court or the Department of Labor (“DOL”). See Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199, 206 (2d Cir. 2015). Accordingly, the stipulation at ECF No. 45 is VACATED.

made the FLSA’s provisions mandatory; thus, the provisions are not subject to negotiation or bargaining between employers and employees.” Lynn’s Food Stores, Inc. v. U.S. ex rel. U.S. Dep’t of Labor, 679 F.2d 1350, 1352 (11th Cir. 1982) (citing Brooklyn Sav. Bank v. O’Neil, 324 U.S. 697, 706–07 (1945)). In accordance with the FLSA’s mandatory provisions, an employer cannot settle claims of unfair wages without approval of the settlement from the United States Department of Labor or a district court. See Wolinsky v. Scholastic Inc., 900 F. Supp. 2d 332, 335 (S.D.N.Y. 2012). Where, as here, the parties seek approval from the district court, they must establish that the settlement is “fair and reasonable.” Persaud v. D & H Ladies Apparel LLC, No. 16 Civ. 5994, 2017 WL 1944154, at *1

(S.D.N.Y. May 8, 2017) (citation omitted). To determine whether a settlement is fair and reasonable, courts consider “the totality of circumstances, including but not limited to the following factors”: (1) the plaintiff’s range of possible recovery; (2) the extent to which “the settlement will enable the parties to avoid anticipated burdens and expenses in establishing their respective claims and defenses”; (3) the seriousness of the litigation risks faced by the parties; (4) whether “the settlement agreement is the product of arm’s-length bargaining between experienced counsel”; and (5) the possibility of fraud or collusion.

Wolinsky, 900 F. Supp. 2d at 335 (quoting Medley v. Am. Cancer Soc’y, No. 10 Civ. 3214, 2010 WL 3000028, at *1 (S.D.N.Y. July 23, 2010)). In addition, courts should not approve agreements that contain “highly restrictive confidentiality provisions” and “overbroad” releases of claims. Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199, 206 (2d Cir. 2015) (citation omitted). Where the proposed settlement provides for payment of attorney’s fees, the Court must separately assess the reasonableness of the fee award. Lliguichuzhca v. Cinema 60, LLC, 948 F. Supp. 2d 362, 366 (S.D.N.Y. 2013) (citation omitted). “In an individual FLSA action where the parties settled on the fee through negotiation, there is ‘a greater range of reasonableness for approving attorney’s fees.’” Wolinsky, 900 F. Supp. 2d at 336 (quoting Misiewicz v. D’Onofrio Gen. Contractors Corp., No. 08 Civ. 4377, 2010 WL 2545439, at *5 (E.D.N.Y. May 17, 2010)). Still, “counsel must submit evidence providing a factual basis for the award,” including “contemporaneous billing records documenting, for each attorney, the date, the hours expended, and the nature of the work done.” Id. II. Analysis The Settlement provides Plaintiff with a recovery of $17,500 inclusive of attorney’s fees and costs. Settlement ¶ 1; see Letter at 1. Plaintiff states that the Settlement “avoid[s] the risk and uncertainty of continued litigation and increasing expenses.” Letter at 3. Further, the Settlement was the product of “arm’s length bargaining,” and the parties were “represented by experienced counsel” in wage-and-hour litigation. Id. at 4.

However, the Court cannot evaluate whether the proposed Settlement amount is reasonable. First, the parties state that “[b]ased upon Plaintiff’s Counsel’s analysis and computation, it is estimated that should he prevail on all issues at trial, Plaintiff’s maximum recovery for his minimum wage and overtime claims ranges from $4,797.00 to $29,380.00, plus liquidated damages, costs, interest and attorneys’ fees.” Id. at 3. The parties cite Plaintiff’s allegations regarding his pay rate and overtime hours worked. Id. at 2. Without supporting declarations or exhibits substantiating the accuracy of his counsel’s “interpretation” or the sufficiency of the amount awarded to him, the Court cannot assess Plaintiff’s range of possible recovery. See Lopez v. Nights of Cabiria, LLC, 96 F. Supp. 3d 170, 176 (S.D.N.Y. 2015) (“At a minimum, the Court requires evidence as to the nature of plaintiffs’ claims, the bona fides of the litigation and negotiation process, the employers’ potential

exposure both to plaintiffs and to any putative class, [and] the bases of estimates of plaintiffs’ maximum possible recovery.”); Mamani v. Licetti, No. 13 Civ. 7002, 2014 WL 2971050, at *1–*2 (S.D.N.Y. July 2, 2014) (listing information that would enable the court to adequately review the proposed settlement). Second, Plaintiff does not provide a detailed description of the risks faced by the parties in the litigation, beyond conclusory statements about the “risk and uncertainty of continued litigation.” Letter at 3. And third, the parties do not state that there was no fraud or collusion in the negotiation process. The Court, therefore, cannot find that the Wolinsky factors are met. In addition, the Settlement contains a liability release that is overbroad in several aspects. Settlement ¶ 3. First, the Settlement releases from liability numerous entities beyond Defendants, including “Defendants’ present, past, and/or former parent corporations, subsidiaries, divisions, affiliated entities, shareholders, successors, executors, officers, partners, members, managers, directors, agents, fiduciaries, owners, employees, representatives, and assigns.” Id.; see also

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Related

Brooklyn Savings Bank v. O'Neil
324 U.S. 697 (Supreme Court, 1945)
LeBlanc-Sternberg v. Fletcher
143 F.3d 748 (Second Circuit, 1998)
Lopez v. Nights of Cabiria, LLC
96 F. Supp. 3d 170 (S.D. New York, 2015)
Wal-Mart Stores, Inc. v. Visa U.S.A. Inc.
396 F.3d 96 (Second Circuit, 2005)
Cheeks v. Freeport Pancake House, Inc.
796 F.3d 199 (Second Circuit, 2015)
Wolinsky v. Scholastic Inc.
900 F. Supp. 2d 332 (S.D. New York, 2012)
Lliguichuzhca v. Cinema 60, LLC
948 F. Supp. 2d 362 (S.D. New York, 2013)

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Bluebook (online)
Galeas v. 1401 Grand Concourse LLC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/galeas-v-1401-grand-concourse-llc-nysd-2024.